On November 9, 2026, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments, effective November 5, 2026, impose sanctions on an additional 38 entities and 24 individuals based on their involvement in “ballistic missile technology development and Russia’s cyber activities”. These measures are also intended to further raise the economic costs of Russia’s war against Ukraine by “targeting financial enablers, including crypto exchanges, that help sustain Russia’s war economy”.

Canada has stated that, as “Russia continues to pursue its war of aggression”, these “new sanctions will help constrain Russia’s capacity to strike civilian targets in Ukraine”. The latest amendments to Schedule 1 of the Regulations target individuals and entities “supporting the Russian defence industrial base and the supply chains enabling Russia’s ballistic missile capabilities” as well as “actors involved in illicit shipping networks, financial and cryptocurrency facilitation, and Russian cyber threat activity”.

We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minister in response to those applications for delisting. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.